Adams v Lindsell – Case Summary

Adams v Lindsell

High Court

Citations: (1818) 1 Barnewall and Alderson 681; (1818) 106 ER 250.

Facts

Adams wrote to Lindsell offering to sell him 800 tods of wool. Adams asked for a response within two weeks. A few days later, Lindsell wrote back agreeing to the offer. However, the letter was misdirected. As a result, it arrived two days after the deadline. In the meantime, Adams had already sold the wool to a third-party. Lindsell sued Adams for breach of contract.

Issue(s)
  1. When did Lindsell’s posted acceptance of the offer become valid?
Decision

The Court held in favour of Lindsell. The acceptance became valid from the moment the letter was posted. There was therefore a contract between Adams and Lindsell.

This Case is Authority For…

A posted acceptance is validly communicated to the offeror as soon as it is posted, even if it arrives late. This is now known as the ‘postal rule’.

Other

The Court argued that the postal rule was necessary to enable distance commerce at the time, since it would be impossible to negotiate a contract by post otherwise. If the acceptance was not immediately valid, the accepting party could not rely on the contract until they had received confirmation from the offeror, and the chain of letters could continue indefinitely.

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